Company WP Advisors, LLC is a privately-held, California, limited liability company that has been providing investment advisory services since 1999 and has been registered with the SEC since 2004. Throughout this disclosure brochure, the company is referred to as "WP" or "the firm" or "we".
The principal owners of WP are Anthony (aka Tony) M. Spangenberg and Stephen (aka Steve) D. Philliber. The firm was co-founded by Tony and Steve in 1999.
Services WP provides the following investment advisory services: Investment Management Services WP provides personalized investment management services to investors. The process starts with gathering required information and setting a confidential meeting to explore a client's financial goals/needs. During this meeting, the client will complete a thorough questionnaire and provide us with any authorizations. WP may also evaluate current financial circumstances through analyses of net worth, income taxes, cash flow and budgeting, investments and asset allocation, retirement planning, employee benefit plan analysis, estate and gift tax planning, education pre-funding and risk management focusing on life, health and disability coverage. The client and WP have the opportunity to have thoughtful discussions about financial planning thus helping to create a risk profile and establish guidelines.
After WP has an understanding of a client's investment goals, risk tolerance and time-frame, a customized portfolio is created as well as a financial plan of action to achieve stated goals. WP will allocate a client's assets among various investments and asset classes. The client's personalized advisory accounts will be constantly monitored and reviewed. Advisory account(s) will be manged on either a discretionary or non-discretionary basis. Clients may place reasonable restrictions on the types of investments which will be made on their behalf. However, WP reserves the right to decline or terminate an account if the restrictions imposed are not reasonable or prohibit effective management of an account.
While financial analyses may include investment advice concerning mutual funds and securities, it may also include investment advice with respect to products that may or may not constitute "securities," such as life insurance and annuities. It also takes into consideration estate tax planning issues that may not represent "investment" advice. Should a client choose to implement the suggestions contained in the analysis, WP suggests the client work closely with a personal attorney, accountant, and/or insurance agent. Implementation of financial analysis suggestions is entirely at the client's discretion. Financial analysis suggestions are not limited to any specific product or service offered by a broker-dealer or insurance company.
In performing its services, WP shall not be required to verify any information received from the client or from the client's other professionals and is expressly authorized to rely thereon. If requested by the client, WP may suggest the services of other professionals for implementation services, but the client is under no obligation to engage the services of any suggested professional. In addition, each client is advised that it remains their responsibility to promptly notify WP if there is ever any change in their financial situation

or investment objectives for the purpose of reviewing, evaluating or revising WP's previous recommendations and/or services.
4 Advisory Services Regarding Retirement Assets WP offers various levels of advisory and consulting services concerning retirement assets. While we do not set up or manage employer sponsored qualified plans, we do manage 401(k) rollover accounts, IRAs, Roth IRAs, single member 401(k)s and other types of individual retirement accounts. WP may also provide advice to the participants of employer sponsored qualified plans when engaged directly by those plan participants. Types of Investments We primarily offer advice on domestic and foreign equity securities, corporate debt securities, commercial paper, certificates of deposit, municipal and United States government securities, mutual funds and exchange traded funds (ETFs), variable life insurance, and options and warrants.
Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2022, the total amount of client assets managed by WP amounts to approximately $338,934,198. Of this total amount, $331,113,498 of client assets are managed on a discretionary basis and $7,820,700 of client assets are managed on a non-discretionary basis. 5